Introduction

This privacy policy (the “Privacy Policy”) describes in detail how Trulinco (“Trulinco”, “us”, “we”, “our”) collects, uses, discloses and/or disposes of personal information in relation to users who havean account with Trulinco and/or in general users who make use of Trulinco Services (as defined hereunder)through our platform known under the name of Trulinco, which is accessible either via the website, desktop or mobile (collectively referred to as “you”, “your”).

Trulinco takes your privacy very seriously and is committed in respecting and safeguarding your privacy and the confidentiality of your personal information at all times, as a matter of priority, when you use any of TrulincoServices.

Trulinco processes personal information in accordance with the obligations under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (also known as the “General Data Protection Regulation” or the “GDPR”) and the Data Protection Act (Chapter 586) of the laws of Malta and all subsidiary legislation thereunder (the latter together with the GDPR shall be collectively referred to as the “Applicable Data Protection Laws”).

Trulinco Services

Trulinco is a multi-lingual cloud application/platform that allows its users to translate documents, text and verbal messages, images, voice calls, video calls and to send and receive text and verbal messages in the preferred language of the user, through its website or mobile app version (“Trulinco Service/s”).

Data controller

The data controller is KBJ LTDbearing company registration number C 94117 and having its registered office situated at Micallef Group, TriqIc-Cimiterju, Ghaxaq GXQ 2248, Malta (the “Data Controller”).

The designated contact person of the DataController is Kurt Micallef, holder of Maltese ID Card numbered 92798M, who can be reached at the email address kurt@trulinco.com.

The Data Controller may be reached by mail at the above registered office address or by email at the email address kurt@trulinco.com. Should you have any queries or require further information with respect to the protection of personal data, kindly do not hesitate to contact us.

Interpretation

All terms used in this Privacy Policy, which are not defined herein, shall have the same meaning as in the GDPR.

What type of personal information do we process?

Identification information and user account details: your name and surname, address, email address, mobile phone number, age, date of birth, gender, account name and password, profile name; we collect information in relation to your gender so that during narration we can use a male or female voice according to gender.

Social networking website user account names: Facebook and any other social media as may be advised from time to time when you choose to connect to Trulinco through such social media accounts.

Information in relation to any payment methods that you may choose, as and when applicable, including credit/debit/pre-paid card information and details as and if provided by you from time to time, as well as your payment history.

Preferences: interests, preferences, feedback and survey responses (where applicable).

Technical and usage data: IP address, login data, browser type and version, make and model of mobile devices, operating system, hardware version, platform, device settings and other technology identification on the devices used to access the Trulinco Services, Bluetooth or WiFi signals, browser plug-in types and versions, operating system and platform, connection information such as the name of your mobile operator or ISP, language and time zone as well as information about how you use the Trulinco Services including redemption of our offers, how you use your devices to access the Trulinco Services, including the screens you visit and searches you make.

Photos, images, videos, voice messages, and any other data uploaded by you on Trulinco and shared with other users or non-users of Trulinco, such as comments, messages, and any other personal information that you may elect to share with other usersor non-users, or any information that, upon your explicit request/consent, is shared with Trulinco for the purposes of providing the Services, such as your address book containing your contacts and telephone numbers. Regarding the contacts, kindly note that we have a contacts’synchronisation feature, which cansynchronise phone numbers from your address book on a regular basis. These numbers are not being stored anywhere. Trulinco is just checking and only those numbers which are already registered with Trulincoi.e.if any of your contacts is not using our Services, wewill manage this information for you in a way that ensures those contacts cannot be identified by us. On the other hand, you can start communication with your contacts who are already using theTrulinco application.

Purpose and legal grounds

Trulinco uses your personal data for specific purposes including the hereunder:

The provision of the Trulinco Services: to operate, maintain and improve the Trulinco Services and related functionalities and features of the TrulincoServices;

Account management: registration, creation and management of your account;

Promotional services: to promote our services and activities from time to time, to provide you with offers and any discounts from Trulinco;

To synchronise your contacts in order to facilitate the sharing of messages from other users of Trulinco, who may already be in your contact list, in your preferred language;

For the purposes of compliance with applicable laws, legislation, regulation and/or any applicable rules to which Trulinco may be subject;

For the purposes of defending any legal claims;

Verification of requests: to verify and process any requests sent by you as per your right to access indicated in Clause 9 of this Privacy Policy;

Address any queries that you may have in relation to the TrulincoServices;

The legal ground for processing your personal information shall be as follows:

Performance of a contract (the Terms of Use of Trulinco);

Legitimate interest (to perform the Trulinco Services efficiently, to keep our records up-to-date, to keep Trulinco updated and relevant, to perform our marketing strategy, to prevent any illegal activities, to defend any legal claims);

Consent (to receive marketing communications by emails, push notifications or texts, to access through your social media accounts, to access your address book);

Legal obligations.

Who do we share your personal data with?

In order to provide the Trulinco Services, we may need to share information with certain third parties as well as internally within Trulinco, as set out hereunder:

Internally: information may be shared internally to any employees of Trulinco;

Suppliers: we share information with certain suppliers used to facilitate the Trulinco Services, for example, our software developers who provide maintenance services and/or email, server, cloud providers;

Social media sites: when you use the Trulinco Services and elect to share information with third-party social media sites, the information you share will be governed by the privacy policies of those social media sites and the privacy settings you have set with those social media websites;

Public authorities and any courts of law when necessary for the fulfilment of a legal obligation, and/or upon request from such public authorities and courts of law, and/or for the purposes of defending any legal claims;

Banks, and auditors: Trulinco may share certain information to the banks where Trulinco holds its bank accounts as well as to the auditors in order to fulfil any statutory or internal audit obligations;

Advisors and service providers: Trulinco may share your information to its accountants, service providers and any other legal, tax or other advisors/consultants engaged by Trulinco to perform certain services as necessary.

Personal data may be shared by Trulinco with entities that are located within the European Economic Area (EEA), which are subject to European Union legislations. Trulinco does not share any personal information with entities that are located outside the EEA. Should there be any instances whereby Trulinco shall be required to share information with entities located outside the EEA, Trulinco shall inform you prior to sharing such information, where and if allowed by law.

How long do we keep your data for?

We will not keep your personal data for longer than it is necessary for the fulfilment of the purposes as set out in this Privacy Policy.

The typical retention period by Trulinco of your data will depend on whether you will continue having an account registered with Trulinco. In such case, Trulinco will process your personal information for the period that your account is active. Trulinco will not retain and consequently will delete your personal information in case of inactivity on your account for a period of two (2) years, subject to limitation as set out in this Clause 8 of the Privacy Policy.

Trulinco shall immediately delete your personal information if you deactivate your account, with the exception of certain personal information (when applicable) that may be necessary to be kept for longer periods in order to comply with legal/statutory obligations or to defend any legal claims, or to be able to respond to any enquiries and/or investigations from any government authorities and/or agencies or courts of law. In the latter cases, the information shall be kept for the time necessary until the said legal/statutory obligation ceases to apply, or the legal claims and/or investigations and/or enquiries are finally concluded up to the last instance, and/or until the risks thereof are finally mitigated or eliminated.

As regards to the material uploaded by the user for translation, the data pertaining to such material is deleted immediately (and not stored) by Trulinco once the translation, or any of the Services used by the client, is provided by Trulinco. Trulinco will give the choice to the user to backup the translation either in their email account or iCloud.

What rights do you have?

Trulinco has taken adequate technical and organisational measures in order for your rights to be respected.

The following are your rights in relation to your personal information:

Right to information: you have the right to be informed on, amongst others, who, how, why, where, when and for how long your personal information is being processed. Should you require any further information, which may not be provided in this Privacy Policy, kindly contact us;

Right to access: you have the right to know what personal data we hold on you. You also have the right to have access and/or obtain copies of such personal data when technically possible and when it does not have a negative impact on other data subjects. You shall have full control to access, view and manage your personal data by navigating through your Profile section on the app or website. However, should you wish to exercise your right to access, you may contact us and we shall make sure that we comply with your request as soon as possible, and in any case not later than one (1) month from the date of the request. When Trulinco is unable to provide the answers within one (1) month due to the high number of requests or the complexity thereof, Trulinco shall inform you and shall comply by not later than two (2) months from the date of your request;

Right to rectification: you have the right to rectify your information in case it is inaccurate or not up to date. In order for you to be able to rectify your information, you can do so by navigating through the setting menu and selecting Profile .The only information that may not be rectified through the setting menu is the mobile number. Should you be unable to update your information or rectify any of your personal data, and should you wish to update your mobile number kindly contact us.In the event that the request pertains to the rectification of the mobile number, a new account shall be created with the updated mobile number.

Right to be forgotten: You have the right to be forgotten and Trulinco has an obligation not to hold your personal information for longer than it is necessary. Should you wish to deactivate your profile, please do so through the setting menu. Should you wish to request Trulinco to have all your data deleted, kindly contact us and we shall respond to your request without delay by deleting your personal information, unless we have reasons of necessity or any obligations to continue holding your data for longer periods. In the latter events, Trulinco shall duly notify you when possible and subject to restrictions set out at law, in reply to your request for deletion of personal data;

Right to portability: when processing of your personal data is based on consent or contract you may require Trulinco to have your data transmitted directly to you or to a third party, when this is technically feasible. Should you wish to exercise this right, kindly contact us;

Right to object: you have the right to object to the way we process your personal information. Should you wish to exercise this right kindly contact us;

Right to withdraw consent: if you have given consent to Trulinco to hold your personal information, and consent is the only legal ground for Trulinco to hold such personal information, you have the right to withdraw your consent. Should you wish to withdraw your consent kindly contact uson info@trulinco.comor unsubscribe from our contact list through the unsubscribe function from the app or at the end of any emails received from Trulinco. Trulinco shall immediately act upon your request; Any requests with respect to payments may be addressed to payments@trulinco.com.

Right to lodge a complaint: Should you have any complaints in relation to processing of your personal data, kindly contact us. In case we were not able to address your concerns you may lodge a complaint with the Information and Data Protection Commissioner.

Cookies

Our website uses cookies to help us provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile devices when you browse websites. Our cookies help us to:

Make our website/app work as per your expectations;

Save you from having to log in every time you visit the website/app;

Remember your settings during and between visits;

Improve the speed and security of the website/app;

Allow you to share pages with social networks;

Continuously improve our website/app for the benefit of our users;

Make our marketing more efficient (ultimately helping us to offer the best and most suitable service for you).

We use the following types of cookies:

Essential – cookies that are essential to provide you with services you have requested (eg. stay logged in on your account);

Performance – cookies which measure how often you visit our sites and how you use them;

Functionality – cookies that are used to recognise you and remember your preferences or settings when you return to our site, so that we can provide you with a more personalised experience;

Advertising – cookies that are used to collect information about your visit to our site, the content you have viewed, the links you have followed and information about your browser, device and your IP address.

You can “Like” or “Share” contents from our platform, app or website on different social media. The privacy implications in relation to the website cookies of such social media will vary from one social network to the other and will be dependant on the privacy settings you have chosen on such respective social networks.

By accepting our use of cookies, you can benefit in full from all the functionalities of our website/app. By not accepting the use of some cookies, you can still access our website/app and view the content therein, however some features of our website/app may not be working properly.

You can turn off cookies by adjusting your browser privacy and security setting to stop it from accepting cookies.

Updates to this Privacy Policy

This Privacy Policy is subject to changes from time to time. Any revision of the Privacy Policy will take effect on the date that it was published on the website. Trulinco invites you to check the Privacy Policy from time to time in order to be informed on the most current one.

This updated version of this Privacy Policy was issued on August 8, 2023.